Subject: File No. 4-606
From: Henry B Lester
Affiliation: Chartered Financial Analyst

April 3, 2013

I have worked with clients of RIA firms for over 25 years. Clients have a reasonably good understanding of the basics of conflicts of interest, fees, and commissions. However, they do not have a good understanding of the structure and the mechanics of the financial services industry that belie their understanding. Simply put, clients do not have enough information, experience or time to differentiate between the advice of advisors subject to multiple standards, and one high standard that puts the clients first is required. Furthermore, we know that clients as well as ourselves are subject to influences and behavioral biases that can be exploited to the detriment of clients therefore, the client must be protected by a uniform fiduciary standard of conduct.